Serbia presents an increasingly compelling jurisdiction for securing an EMI licence to enter into the EU market. Despite falling short of full membership status, Serbia’s aligning financial regulations, stability, cost efficiency, talent pool, and trade privileges improve its credentials as a springboard for regional expansion.

Enacting updated payments laws in 2014, Serbian legislation resonates European licensing and reporting standards for electronic money/payment services providers. This confers improved standing for licensees targeting the wider bloc. Ongoing EU accession also incentivises Belgrade to continuously elevate supervision.

Beyond regulatory fluency, Serbia’s workforce, lower-cost real estate, energy and transitional services, and generous free trade zones cultivate an efficient base for payments firms to scale operations. Double taxation accords also prevent excessive liabilities abroad.

Offering regulatory alignment, operational incentives and regional access, Serbia holds widening appeal as a strategic jurisdiction amid its trajectory towards deeper European financial integration.

Procedure for obtaining an EMI licence in Serbia

Pursuing an EMI licence enabling the issuance of electronic money and provision of payment services in Serbia necessitates certain prerequisites.

Qualifying companies must establish themselves as registered legal persons under prescribed business forms that confer limited liability protections, such as an LLC, JSC, or other forms that comply with local legal requirements.

Robust technological infrastructure and systems safeguarding data security and integrity are imperative to ensure compliant and resilient electronic money and payment operations. Ongoing availability of expert technical personnel for system maintenance and continuous compliance monitoring is similarly essential.

Meeting capital requirements is integral for seeking Serbian EMI authorisation. Applicants must evidence a minimum fully paid-up share capital of €20,000 when submitting licensing materials, subject to activity-specific thresholds. This capitalisation provides guarantees on solvency, critical for maintaining creditor and customer protections in delivering regulated payment services.

Satisfying these eligibility criteria lays the groundwork for progression through the EMI licensing process in Serbia and the launch of compliant electronic money issuance. Ongoing preservation of all prerequisites enables continuity of licensed operations.

Serbia EMI licence application procedure

The licensing process mandated by Serbian authorities encompasses several key stages for aspirant issuers and payment service providers.

  • Stage 1 demands registering the applying entity as an appropriately corporate body per Serbian commercial law, evidencing adequate fully paid-up share capital, detailing electronic money operating intentions and risk management protocols in a comprehensive business plan, and instituting secure technological systems and supportive expertise protecting data integrity and operational resilience.
  • Stage 2 involves filing formal licence application documentation to the National Bank of Serbia demonstrating conformity with all stipulated conditions and requirements in a complete evidentiary manner.
  • In Stage 3 applicant submissions undergo intensive scrutiny by National Bank evaluators assessing institutional financial viability, infrastructural robustness, risk preparedness, and legal compliance capacities based on applicable electronic money and payment services regulations.

The satisfactory fulfilment of requisites across the preceding stages may enable the National Bank’s issuance of an EMI licence in Serbia authorising commencement of regulated activities. Throughout the application process and subsequent licensed operations, maintaining high standards of institutional transparency, operational security, and legal compliance remains imperative amidst close National Bank supervision.

Operational requirements for payment systems with an EMI licence in Serbia

Operating a compliant payment's infrastructure in Serbia necessitates implementing robust technological architectures and controls across various functional domains.

Fundamental considerations in designing system architecture include:

  • employing reliable and scaleable transaction processing engines,
  • instituting strong multifactor authentication methods,
  • building versatile integration gateways for diverse payment origination channels,
  • enabling rapid settlement finality,
  • supporting omnichannel servicing capabilities.

Prioritising security and fraud prevention is imperative across architecture, adopting encryption, tokenisation, cryptography, firewalls, access restrictions, cybersecurity preparedness, and resilience testing while also meeting Serbian regulatory reporting obligations.

Vetting external technology solutions warrants clearly defined evaluation criteria assessing integration complexity, efficiency, reliability, and vendor dependencies.

Ongoing monitoring of performance dashboards on transaction volumes, values, disputes, reversal rates, and system uptime should inform capacity planning and infrastructure investment.

Effective technology governance necessitates collaboration between business units, developers, quality assurance teams, and dedicated Chief Information Security Officers to continually align priorities between commercial objectives, operational excellence, and risk management.

While relying substantially on external technology vendors is commonplace, EMI operators in Serbia retain accountability for overall payments infrastructure and security. This demands ensuring adequate in-house technical skills and strategic influence over third-party technology decision-making.

Legal requirements for entering the EU market with a Serbian EMI licence

Serbian EMI licence holders seeking scaling into European Union member states must satisfy various ongoing prudential and consumer protection obligations.

  • Minimum requirements mandate appointing two qualified managers with substantiated expertise across payments, finance, economics, or technology disciplines. Maintaining Serbian operations across a dedicated local entity with sufficient capital buffers against operating risks remains imperative given conduct accountabilities stemming from cross-border activities.
  • Prior to market entry, detailed business plans and risk models explaining how transactions, information security, fraud monitoring, and customer servicing will comply with EU laws amidst expansion must be submitted for regulatory approval.
  • For EU customers, providing multilingual account services, dispute resolution mechanisms and documentation in official national languages is compulsory while strictly observing EU regulation terms on confidential data use, storage, and transparency.
  • Safeguarding payment infrastructure and customer data via advanced encryption, cybersecurity systems and staff training to meet Europe’s PCI Data Security Standard constitutes another prerequisite to maintaining passporting rights.

Ongoing adherence to these requirements relies on effective governance structures for continually monitoring legal and regulatory developments across relevant EU jurisdictions and Serbian authorities. Building compliance management capacities and productive regulatory relationships represent crucial investments when leveraging Serbian EMI licences to access wider payment services markets.

Possible challenges in obtaining a PSP licence in Serbia

Payment services providers in Serbia can encounter obstacles during licensing pursuits stemming from exacting regulatory burdens, demanding technology prerequisites, and intricate compliance intersections.

  1. Stringent capital, cybersecurity, infrastructure resilience, and risk governance standards imposed on licensees necessitate substantial upfront and ongoing investments. Rigorous scrutiny around anti-money laundering protocols, transaction monitoring, and customer due diligence creates additional compliance complexities.
  2. Meeting international best practices by implementing multi-layered data encryption, access controls, and vulnerability testing to satisfy Serbia’s PCI DSS and EU GDPR is a must. Nuanced localization around permitted payment channels, partner integration, and product development is equally vital.
  3. Formation of exhaustive policies, operational manuals, capital models, and executive background checks per licensing directives generates prolonged timelines. Gaps in technical specifications or internal capacity frequently trigger requests for clarifications, enhancements and resubmissions, thereby delaying approvals.

Mitigating these challenges relies on cultivating specialized legal, finance, and technology talent; allocating adequate budgetary provisions; instituting robust project governance; and maintaining open regulatory dialogue. Further, leveraging expert advisors could enable more fluid support on obtaining EMI licence in Serbia.

Acquiring a company with an EMI licence in Serbia

Acquiring a firm holding Serbian EMI licence requires methodical execution across prerequisite due diligence, transfer approval procedures, and post-purchase restructuring.

The process begins with a legal assessment verifying the target’s licensing, good standing regulatory track record, financial viability, and growth prospects under new ownership.

With positive indications, the next stage commences by filing change in control applications with the National Bank of Serbia, including nominations for incoming directors and senior managers meeting fit and proper criteria.

Upon securing regulatory approvals, revised risk models, product suites, technology stacks, and distribution capacity more aligned with the acquirer’s commercial priorities are implemented. Updating relevant documentation and ensuring personnel continuity throughout is equally vital.

Whilst enabling swifter market entry than licensing from scratch, buyouts pose inherent risks requiring mitigation. Acquirers must gauge past conduct, disputes, infractions, or relevant intellectual property compromises that could resurface reputationally or operationally post-transaction.

Transitioning existing operations also warrants maintaining customer servicing continuity whilst aligning accounts, payments channels, and support systems with the purchaser’s offerings.

Overall, realising the advantages of acquiring a Serbian firm with an EMI licence demands extensive legal, financial, commercial, and technological due diligence for ensuring regulatory compliance, implementing the target’s infrastructure securely under new management, and adding strategic value.


Pursuing EMI licence in Serbia to conduct payments activities requires substantial investments in legal, technological, and operational capabilities for meeting European standards.

Amidst its pursuit of European Union accession, Serbia imposes stringent checks around capital, risk modelling, infrastructure safeguards, cybersecurity, and compliance expertise mirroring EU frameworks to uphold financial system integrity.

Whilst the licensing process obligates strict local incorporation, reporting, and multilingual servicing, market expansion potentials are noteworthy. This enables Serbian licensees extensive privileges to doing businesses across the continent.

Realising these, however, relies on building bespoke technological stacks, customized interfaces for regional customer bases, and specialized skillets navigating intersecting EU directives and Serbian regulations while also liaising closely with oversight bodies.

We provide detailed information and full support in the process of obtaining an EMI licence in Serbia. Choose a method convenient for you from the “Contacts” section to contact our experts.